Michael W. and Charlotte S. Phillips - Page 1

                                   106 T.C. No. 7                                     

                               UNITED STATES TAX COURT                                

                MICHAEL W. AND CHARLOTTE S. PHILLIPS, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4745-94.               Filed March 7, 1996.                 

                    Ps contend that they avoided recapture of an                      
               investment credit claimed with respect to property of a                
               partnership subject to secs. 6221 through 6231, I.R.C.,                
               as a result of filing an amended return revoking the                   
               credit subsequent to the disposition of the property.                  
               Held:  The amended return was ineffective because it                   
               did not conform to the requirements of an                              
               administrative adjustment request under sec. 6227,                     
               I.R.C.  Held, further, Ps were required to take into                   
               account their distributive share of the partnership                    
               investment credit, and conversion of their partnership                 
               items to nonpartnership items pursuant to the filing of                
               a bankruptcy petition did not affect this obligation,                  
               nor preclude R’s use of a prospective partnership level                
               settlement as the basis for computing Ps’ personal tax                 

               Joseph B. Schimmel and Alan R. Chase, for petitioners.                 
               Ellen T. Fribourg and James P. Dawson, for respondent.                 

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